Illinois Health Care Reform Implementation Council releases initial recommendations

States have been active in analyzing the reform requirements of the Patient Protection and Affordable Care Act (ACA) during the past year. Many have formed task forces or commissions to sort out those requirements. Illinois is among the states that has taken action.

The Illinois Health Care Reform Implementation Council, which Governor Pat Quinn established via Executive Order #10-12 in July 2010, has issued its initial report on how Illinois should implement the ACA.

The report indicates the council’s recommendations fall into two categories: issues that the state must address immediately, and decisions that will be made after the council gathers more information from stakeholders and the federal government provides additional guidance.

Health insurance exchange. Foremost among the immediate recommendations is to establish a health insurance exchange for Illinois, governed by a quasi-governmental authority. Other recommendations describe its nature and scope, including initially organizing the exchange as a “market developer” and later transitioning to a “market organizer” model once premium volume and a sufficient number of covered lives are achieved within the exchange marketplace.

According to the report, the council recommends that Illinois initially establish a single exchange entity that sells products to both individuals and small employers. The council also recommends that the state revisit merging the individual and small group risk pools after it receives additional information and analyses of the marketplace and the potential impact of this option.

Insurance protections. The report also indicates that the council recommends immediate action to provide Illinois consumers with the same health insurance protections contained in the ACA to assure fairness and affordability. These protections include:

• internal appeals and external review,
• minimum medical loss ratios, and
• premium rate review.

According to the report, the council recommends that Illinois law be amended as necessary to remove barriers and facilitate formation of nonprofit member corporations eligible for federal funding under the ACA.

Other issues and next steps. The report indicates the council recommends further study on whether Illinois’ definition of “small employer” should be increased from 50 to 100 employees and whether larger employers should be allowed to participate in the exchange.

In addition, the council recommends waiting for further guidance from HHS before deciding whether to require benefits beyond the “essential benefits” defined by HHS. The report explains, “Some of Illinois’ existing benefit mandates may not be included in the definition of ‘essential health benefits.’ The ACA allows states to require qualified health plans offered in the Exchange to provide benefits in addition to the “essential health benefits.” However, states must pay for any portion of subsidized coverage that is attributed to the cost of those additional benefits. The state could consider funding these mandates separate from the Exchange.”

Council process. The council conducted four public meetings in Chicago, Peoria, Carbondale, and Springfield focused on the following issues:

(1) establishing a health insurance exchange and related consumer protection reforms;

(2) reforming Medicaid service structures and enrollment systems;

(3) developing an adequate workforce;

(4) incentivizing delivery systems to achieve high-quality health care;

(5) identifying federal grants, pilot programs, and other non-state funding to assist with implementation of the ACA; and

(6) fostering the widespread adoption of electronic medical records and participation in the Illinois Health Information Exchange.

In addition, the council solicited written comments regarding a series of specific questions concerning implementation of the insurance exchange in Illinois. A fifth public meeting was held in Chicago in February for stakeholders to question and react to the initial recommendations submitted by the council on February 3. Overall, more than 150 individuals and organizational stakeholders shared their suggestions with the council.